Canadian Pacific Railway Company Reply and Answer to Undertakings

REDACTED PUBLIC VERSION

Agency Case No. 19-00189

In the Matter of an Investigation pursuant to subsection 116 (1.11) of the Canada Transportation Act, S.C. 1996, c. 10, as amended,

Initiated by LET-R-6-2019

Canadian Pacific Railway Company Reply and Answer to Undertakings

Canadian Pacific Railway Company Building One, 7550 Ogden Dale Road S.E. Calgary, AB T2C 4X9

Cassandra P. Quach General Counsel – Regulatory Tel: 403-319-7016 Fax: 403-319-6770 REDACTED - PUBLIC VERSION

Contents Introduction ...... 3 Procedural Fairness ...... 3 CP’s Record Performance Across Key Commodities ...... 4 Grain ...... 4 Forest Products ...... 5 Supply Chain Issues, Terminal Planned and Unplanned Shutdowns ...... 5 CP’s Embargo Process ...... 6 When or Why CP has challenged Embargo Process...... 8 CP’s Communication ...... 8 Vancouver Dwell Details ...... 8 Publicly Available Dwell Data and Methodology ...... 9 Vancouver Area Dwell Data & Methodology ...... 9 Vancouver Terminal Dwell Performance ...... 10 Locomotive Operations in the Vancouver Terminal Area ...... 13 Train Swaps ...... 13 Cooperative Operations in the Vancouver Terminal Area ...... 14 CP’s Capital Investments ...... 15 Concluding Remarks ...... 16 Appendix 1 – CP Grain Volume Press Releases ...... 17 Appendix 2 – CN Embargo Public Notice ...... 19 Appendix 3 – CP Embargo Bulletins ...... 21 Customer Station Bulletin ...... 21 Customer Advisory – Vancouver Traffic Embargo ...... 21 December 18, 2018 Customer Station Bulletin ...... 22 Carload Network Bi-weekly Update – Week of December 17, 2018 / Nouvelles bimensuelles – Transport de wagons complets – semaine du 17 décembre 2018 ..... 22 Customer Station Bulletin ...... 23 Customer Advisory – Vancouver Traffic Embargo Changes ...... 23 Customer Station Bulletin ...... 24 Customer Advisory – Vancouver Traffic Embargo Changes - Clarification ...... 24 Customer Advisory – Vancouver Traffic Embargo ...... 24

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From: Embargo Permit DB System ...... 25 From: Embargo Permit DB System ...... 29 From: Embargo Permit DB System ...... 31

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Introduction Canadian Pacific Railway Company (CP) is pleased to provide the following reply to submissions made by other participants and answers to questions posed to CP during the public hearing held in Vancouver on January 29th and 30th, 2019. CP notes that CP has, in so far as practicable and reasonable, complied with all prior directions to provide an enormous amount of information and data in CP’s possession that are relevant to the issue within the 3 days given under the letter decision LET-R-6-2019, as well as all with all further requests for information and data to date. Additionally, CP participated in the public hearing to respond to the Inquiry Officer’s Report dated January 24th, 2019 and be available for further questions despite the extremely rushed timeline. In the same hurried pace, CP has prepared this reply and further answers to the broad questions posed at the public hearing. Throughout, CP has put forth its best efforts. However, despite these efforts, given the time constraints, the lack of clarity of the actual service failure that is alleged to be at issue, and most importantly, the lack of any substantive information or evidence provided by any shipper, or classes of shipper, or associations representing them, this CP’s reply and further answers cannot and should not be taken as CP’s full and final answer, and should be read together with all information previously provided. Thus far, after reviewing the Inquiry Officer’s Report dated January 24th, 2019 and listening to the information provided at the public hearing, CP remains of the view that there is no evidence of freight service failure in the Vancouver area, certainly none involving CP. In fact, the following additional information will further support CP’s position that CP has met its service obligations.

Procedural Fairness Procedural Fairness is the cornerstone of legitimacy of any regulatory regime. This aspect is so fundamental that CP is compelled to once again demand that procedural fairness is afforded to CP throughout, as CP is deeply concerned that it has been lacking to date. As stated by Chairman Streiner, the Canada Transportation Agency (Agency) is an “independent expert tribunal and regulator” which has “in respect of all matters necessary for the exercise of its jurisdiction all the powers of a superior court.”1 As a quasi-judicial body, now endowed with own-motion investigative powers, the power to compel information and attendance for questioning, it is imperative that the Agency exercise of this extraordinary power within the proper safeguard of procedural fairness. As stated by CP at the public hearing, despite the time constraints, CP had made its best efforts to prepare and participate in the investigation. That effort was not reciprocated. Not a single shipper in its own capacity attended the public hearing, or, to the best of CP’s knowledge, submitted any information or data at any other stage thus far in this investigation. The various shipper organizations that did attend the public hearing did not come with any concrete information, objectively verifiable data, or demonstrable evidence of service failure in the

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Vancouver area. The record remains bare of any substantial evidence submitted by or on behalf of the shippers. CP remains in the dark to deal with anecdotes, assertions, and broad and vague grievances into “possible freight rail service issues in the Vancouver area.” To date, the only information and data on the record are those supplied by CP (and presumably those of Canadian National Railway Company (CN) and BNSF Railway Company (BNSF), which information is being used against CP. The continuation of any investigation against CP in the face of the lack of concrete evidence of service failure by CP would be procedurally unfair. The continuation of demands for CP to provide information and data without full particulars as to the precise service issue under investigation would be procedurally unfair. These are serious allegations, ones that CP does not take lightly, and as such the need for procedural fairness is heightened. Unless otherwise indicated herein, CP continues to rely on all submissions previously made.

CP’s Record Performance Across Key Commodities Grain The following table shows CP grain traffic moving through the Port of Vancouver area during the CTA study period. CP moved record volumes through the Port during the 2018-19 study period. Total grain volumes during these 4 months grew by 15%, year over year (from 62,197 loads to 71,495 loads), and by 23% from 2015-16 to 2018-19 (from 58,081 loads to 71,495 loads).

Grain Traffic to Vancouver CTA Study Period (October-January) 80,000 70,000 60,000 50,000 40,000 30,000 20,000 10,000 0 2015-16 2016-17 2017-18 2018-19 Tank Cars Intermodal Hopper Cars Total

CP issued two press releases in November and December of 2018 announcing all-time record grain volumes, including record volumes to Vancouver in November (see Appendix 1).

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Forest Products CP’s service in the forest products sector has seen an increase year-over-year. As shown in the following table, CP’s total traffic in the forest products segment increased by 10%, year-over- year, in the 2018-19 study period, and increased by 12.1% over the study period.

All Forest Products, Carloads CTA Study Period Line of Business Month 2015-16 2016-17 2017-18 2018-19 Lumber & Panel OCT NOV DEC JAN Other Forest Products OCT NOV DEC JAN Pulp & Paper OCT NOV DEC JAN Grand Total, Carloads 20,852 20,080 21,244 23,369 Growth, Year-over-year -3.7% 5.8% 10.0% Growth over the study period 12.1%

The Pulp & Paper line of business increased from 12,587 carloads in 2017-18 (October to January) to 14,135 carloads in 2018-19 over the same period. This is an increase of 12.3%.

Pulp and Paper only, Carloads CTA Study Period 2015-16 2016-17 2017-18 2018-19 Pulp & Paper 12,803 11,533 12,587 14,135 Growth, Year-over-year -9.9% 9.1% 12.3% Growth over the study period 10.4%

It is the shipper who determines the destination for its traffic, and CP is not privy to the reason why one region may be favoured over another at different times. However, the volume data above indicates that the traffic on CP’s network is indeed moving to alternative regions. As presented by other participants in this investigation, pricing for forest products to the Asian market has been weak in recent months. This may account for the reduction in the volume shipped to the Vancouver terminal area. Despite the fact that several market factors have recently weighed against the forest products sector in Canada, CP’s traffic in these lines of business has grown considerably. This clearly demonstrates that CP has not been discriminating against this market sector.

Supply Chain Issues, Terminal Planned and Unplanned Shutdowns CP tracks terminal shut-downs and slowdowns for the major Vancouver terminal facilities. The following table shows the number of days impacted, by cause, for the period of October through

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December of 2018. Note that the “Other” category includes a number of potential causes, including but not limited to weather, “slow” unloading, port congestion, and terminal congestion.

CP Major Terminals – Operating Days Impacted, October through December, 2018

Shut-downs Slow-Downs Total Mechanical & Full Partial Staffing Maintenance Other North Shore Terminals 14 7 3 24 87 135 South Shore and Other 11 8 31 37 34 121 Total 25 15 34 61 121 256

There are 92 calendar days in this period. Over the nine terminal facilities shown there are 828 available operational days. Of these, a total of 256 days were lost to shutdowns or significantly impacted by slowdowns. Nearly one third of the available operational days were negatively impacted. Taking into account the fact that some facilities do not operate 7 days per week, 24 hours per day, this figure is actually an under-representation of the true impact. When terminals are not operating at full capacity, this impacts the entire supply chain. Incoming trains must be held away and staged, increasing congestion on the network. Planned power and crew connections must be re-scheduled, which negatively impacts operating plans and manpower planning. Shippers may need to delay their planned shipments, or select alternate destinations, because capacity is not available at the terminal.

CP’s Embargo Process As stated in CP’s presentation, CP uses embargoes and permits as a tool of last resort to control traffic movements when there is actual or threatened operational impairment that is temporary in nature. Within the last several years CP has only implemented three embargoes in the Vancouver area. These were all in December of 2018. As such, CP’s experience with embargoes is limited, but will point to Columbia Container Terminal (“Columbia”) as an example of the rationale that was used in that case.

CP considered the following factors in determining whether it was necessary and thus, reasonable, to issue an embargo with permits on Columbia:

· Receiver spot capacity - Columbia car spot capacity is 35 cars but they take an average of 25 cars per spot due to product mix and unload capabilities. · Inventory on-hand - It would be reasonable to have 2-2.5 days of traffic on hand in the Vancouver terminal area. Once we move past this level, if we allow a single facility to back up to 3x-5x its normal inventory, the backlogged cars in queue are consuming other customers’ capacity/track space.

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· Communication - CP worked closely with Columbia, who was being impacted by large blocks of CN traffic, to find other ways to manage the flow of traffic. As evidenced in the chart below, those efforts failed to reduce the inbound pipeline to a manageable level.

The chart below will describe the following months leading up to our Embargo Notice on Dec 21st:

· The straight lines charted below describe the average daily cars requested and spotted by Columbia year over year for this time frame – of note service was much more consistent in 2018/19 vs 2017/18 in spite of increased volume. · The stacked bars charted represent CP and CN average daily cars on hand for the week during this time period. This is overlaid with the dotted lines that chart average daily cars on hand in the yard for each month year over year. Note the significant uptick in CN originated volume. · The bright Yellow line indicates the day Embargo Notice was provided, December 21st, effective December 23rd.

Columbia Containers Weekly Average # of CP / CN cars in Vancouver Week & Total Cars Spotted (2017-18 vs 2018-19)

200

180

160

140

120

100

0 Oct-01 Oct-08 Oct-15 Oct-22 Oct-29 Jan-07 Jan-14 Jan-21 Nov-05 Nov-12 Nov-19 Nov-26 Dec-03 Dec-10 Dec-17 Dec-24 Dec-31 Avg CN (2017-18) Avg CP (2017-18) Avg CN (2018-19) Avg CP (2018-19) Monthly Avg Serving Yard Count 2017-18 Monthly Avg Serving Yard Count 2018-19 Avg Cars Requested (2017-18) Avg Cars Spotted (2017-18) Avg Cars Requested (2018-19) Avg Cars Spotted (2018-19)

For all CP customers with traffic destined on CN, CP monitors the dwell time associated with Interchange to CN. CP started seeing a pattern of CN being unable to accept Interchange traffic

Page | 7 REDACTED - PUBLIC VERSION at the end of November, as was evident in the number of Transfer of liability (TOL) that were rejected. As evidence of the degree of backlog, in December 2018 CP was holding 1623 cars that were TOL transferred, with an average dwell of 5 days until the cars were accepted at interchange.

CP had to ensure that the North Shore did not create a throughput bottleneck inside CP’s yards. CN’s inability to accept CP’s cars directly impacted CP’s serving yard and reduced its capability to service all customers. In summary, the embargo was required to preserve network fluidity.

When or Why CP has challenged Embargo Process Given our labour disruption effective 2200 EST May 29, 2018, CN per notice to customers (CN Labour Update) as provided in Appendix 2, went out with an embargo notice in front of CP’s own embargo declaration. CN’s embargo notice would have been effective prior to the strike date and CP was still working diligently on negotiations with our running trades. CP worked with CN and the AAR, and CN subsequently cancelled their initial notice (below).

CN’s embargo notice is provided in Appendix 2.

CP’s Communication As discussed during the oral hearing, CP provides multiple channels of communication to ensure that shippers are aware of the implications of embargoes and other pipeline issues. CP’s embargo bulletins distributed to customers are provided in Appendix 3.

Vancouver Dwell Details Dwell for the Vancouver terminal is measured both at the railyard level as well as at the greater terminal area level. The former is published weekly on CP’s corporate website, while the latter is used internally to understand and manage the performance of the local operating area for which the management team is responsible.

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Publicly Available Dwell Data and Methodology Dwell data for key terminals on CP’s network is published weekly to CP’s website at www.cpr.ca. Terminal dwell is defined as follows (source www.cpr.ca) “Terminal Dwell is the average time a car resides within terminal boundaries expressed in hours. The measurement begins with a customer release, received interchange, or train arrival event and ends with a customer placement (actual or constructive), delivered or offered in interchange, or train departure event. This will exclude stored, bad ordered, and maintenance of way cars.”

For the Vancouver terminal this data reflects railcar dwell at Coquitlam yard. Dwell performance in Vancouver for the 4th quarter of 2018 was 6% better than the 4 year weekly average, and 21% better than Q4 2017.

Vancouver (Coquitlam Yard) Dwell 2015 - 2018 18.0

16.0

14.0

12.0

10.0

Average Average Hours / Railcar 8.0

6.0 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 2015 2016 2017 2018 Average Dwell 4 Year Average Top Quartile Weekly Dwell

The improvement in the measured dwell Q4 2018 occurred as CP was moving record volumes through the Port. Vancouver Area Dwell Data & Methodology The Vancouver Terminal area encompasses the entire lower mainland in which CP operates. Any railcar that enters this terminal area, either through a customer release or interchange event, or through a train arrival event, is measured as part of CP’s Terminal Scorecard. For the Terminal Scorecard the calculation of dwell is similar to that of the publicly disclosed data, however the definition of the “terminal” is expanded to include the local operating area for which local management is responsible – this “all in” view of the terminal is a key component of CP’s management system.

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In the terminal scorecard the dwell clock starts with the first event within the terminal – typically this is a train arrival event on inbound traffic, and either a release or interchange event for outbound traffic. The dwell clock stops with either the delivery of the railcar to the customer or connecting carrier (constructive or actual), or with the departure from the terminal on an outbound train.

Vancouver Terminal Boundaries (shaded area) as defined for the Terminal Scorecard (TSC)

Vancouver Terminal Dwell Performance Terminal dwell performance for the greater Vancouver Terminal area improved by 11% in Q4 2018 over Q4 2017, continuing the trend of improvement observed over the past few years.

Total Terminal Dwell - Vancouver Terminal 2015-2018 25

5 Average Average Dwell Hours per Car 0 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 2015 2016 2017 2018

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As evidenced in the following chart, drivers of improved dwell year over year are principally the outbound shipments from release at customer / receipt at interchange to depart Vancouver terminal. CP would like to note that the mix in line-of-business volume levels can have a material impact on year over year measures in dwell. For example, more unit train business to a high capacity terminal on the South Shore might drive dwell down, overall.

Definitions:

- To Customer = from arrive terminal to constructive or actual placement at customer facility - To Interchange = from arrive terminal to offered or actual interchange - From Customer = release from customer facility to depart terminal - From Interchange = from interchange receipt to depart terminal - Other/Mix = impact of change in volumes by business segment and other factors

Inventory and Dwell Inventory levels in the Vancouver Terminal area grew through Q3 and Q4 2018 – this was a function of the increased volumes following into the terminal as well as higher inventory levels both within the Terminal and at customer facilities.

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Vancouver Terminal Dwell and Inventory Levels Q3-Q4 2018 4,500 25 4,000 3,500 20 3,000 15 2,500

Cars 2,000 10 1,500 1,000 5 500

0 0 Car per Hours Dwell Average

Week Started Active Inventory Inbound Train To Interchange Dwell To Customer Dwell

The increase in inventory in the Vancouver Terminal in the fourth quarter is consistent over time, with similar increases in past years. While it is impossible to isolate any single cause of congestion, it is clear that increased levels of inventory are a normal seasonal occurrence and correlate to increased demand, more challenging operating conditions, and reduced supply chain partner operating hours through the holiday season.

Vancouver Terminal Area Inventory 2016 - 2018 5000 16 4500 14 4000 12 3500 3000 10 2500 8 2000 6 1500 4

Cars in Active Cars in Active Inventory 1000

500 2 Average Dwell Hours Per Car 0 0 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 Qtr1 Qtr2 Qtr3 Qtr4 2016 2017 2018

Average of Active Inventory Terminal Dwell (Total)

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Locomotive Operations in the Vancouver Terminal Area CN and CP share locomotives routinely in the Vancouver area in accordance with the Co- Production (Co-Pro) agreement which has CP operating all traffic destined to the South Shore (except CN intermodal traffic), while CN operates all traffic to the North Shore.

Beyond the operations described above, CP did not provide any loans of CP locomotives to CN over the study period.

Train Swaps For the purposes of this discussion, a “train swap” is defined as a change of the destination terminal for a given train after that train has already been waybilled. This discussion only considers train swaps from a North Shore destination to a destination that is not on the North Shore, or vice-versa. Because CP does not determine the final destination for the customer’s traffic, it is not in a position to engage in train swaps directly. However, CP does process the orders for a change of destination, so it knows when a train swap has occurred. Train swaps are only possible where a viable terminal destination exists on both the North Shore as well as on the South Shore or elsewhere in the Vancouver terminal area. This situation exists only for shippers of coal, sulfur and grain.

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Note that it is possible that shippers selected alternate destinations within the Vancouver terminal area before the affected train was waybilled. CP would not be aware in those cases.

Train Swap Details:

Shipper Diversion Date Original Destination Final Destination

Cooperative Operations in the Vancouver Terminal Area We have a very open line of communication at a General Manager, Superintendent and Assistant Superintendent level which allows us to run a solid plan or make a change that is agreed upon by both parties. As mentioned previously, communication between the railroads is more-than-daily. Following are some of the regular strategies that are used to ensure efficient utilization of the available network assets and ensure maximum throughput of the Vancouver terminal area: ü Crew management - We jointly manage the Co-Pro agreement to keep an equitable balance of crew share for both CN/CP trains. ü Centerm, Vanterm car share – we apply a simple strategy whereby the traffic that is spotted by CN is normally reloaded with CP Traffic, and traffic that is spotted by CP is normally loaded back with CN Traffic. This reduces the re-handling of cars in the Port area. ü Deltaport is managed as a pool of cars which is equitably shared by CP and CN. ü There is an email daily distribution whereby CP advises CN what we have for Interchange traffic moving from Coquitlam to Thornton Yard. ü Sapperton is used to balance out the coal and potash moves to Neptune. ü We also take interchange delivery of grain empties coming from the North Shore which helps cycle customers’ cars faster.

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ü CP will set off the mid-train remote locomotive before the train enters the lower mainland, so that CN can take the train direct to the terminal without re-marshalling.

All of the preceding occurs within the over-arching context of the Co-Pro agreement which greatly streamlines the fluidity and capacity of the Vancouver terminal area.

CP’s Capital Investments When solving to capacity in the lower mainland, capital investments in infrastructure such as that proposed by the NTCF are critical. Having said that, infrastructure investment as far away as Calgary supports Vancouver terminal’s success. Late in 2018, CP invested considerable capital in its Calgary terminal. This investment provided additional classification capability, and supports the building of additional blocks to reduce the dependency on other terminals, including Vancouver. Significant investment was also made at our Calgary intermodal facility, again with the intent of improving the reliability of our service to and through Vancouver. Lower Mainland Prior to 2018, CP had modified tracks in the lower mainland between Pacific Coast Terminals and West Coast Reductions. This created individual access leads to enable more than one assignment to service at the same time. Specifically, this work made three independent leads: i) the CN lead track to West Coast Reduction, ii) the L Lead to Vanterm East and iii) the Waterfront Lead to Pacific Elevators. The three new leads were created to improve operations and allow CP and CN to work collaboratively to service these three customers. Building capacity In 2018, network infrastructure improvements focused on increasing train-meet flexibility. In the Calgary to Vancouver corridor CP extended two sidings to accommodate longer trains, achieve faster transits and reduce congestion in the corridor. This improvement reduced train wait times, reduced subdivision transit time and created overall network capacity. The Keith siding extension was placed in service in May 2018. This siding was increased by 4,200 feet enabling longer trains to meet and pass one another just minutes west of Calgary, instead of crowding-up Calgary’s busy terminal. Cambie siding, situated in a high volume traffic area on the Shuswap subdivision, was extended by almost 5,000 feet. This extension significantly reduced delays for train meets and created more flexibility in recovering transit times in the event of network disruptions or planned maintenance work. Track Maintenance

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In 2018, on the Calgary to Vancouver main line, basic replacement track and infrastructure upgrades included replacing 26 miles of ballast and just over 46 track-miles of new rail, replacing roughly 57,000 cross ties and 17 turnouts, eliminating 2,600 joints and doing 23 miles of track gauging. Track and structures maintenance required for various bridges, tunnels and sheds, culverts and road crossings, in addition to signals and communications systems upgrades. A two year maintenance program started in 2018 in the Connaught Tunnel on CP’s Mountain subdivision. The work includes rail, ties and ballast replacement. At CP we strongly believe that a comprehensive investment strategy across our network and through the supply chain is required to enhance the Vancouver terminal area’s capacity and reliability.

Concluding Remarks CP repeats that the evidence clearly demonstrates that there was no material freight service issue, particularly, any that was caused by CP’s operations, · There was no differential treatment of any shipper, classes of shippers or certain commodities by CP;

· The imposition of embargoes was necessary, measured and reasonable;

· CP operations in so far as serving its line haul shippers met, and in most cases exceeded historical levels, and where there were operational challenges with interchange traffic, they were temporary and CP was accommodating and performed extra work, such as blocking traffic for CN to increase fluidity. CP’s operations remain fluid today;

· CP is optimizing its existing infrastructure and has made and will continue to make responsible and sustainable investments to accommodate projected growth in demand; and

· CP was engaged with its shippers, terminal operators, and others in the supply chain, at all levels of the organization to ensure that all stakeholders are properly informed. CP has met its service level obligations, providing the highest level of service in respect of those obligations that CP can reasonably provide, in the circumstances. CP has provided adequate and suitable accommodation for traffic, including the interchange of traffic from connecting carriers. CP remains of the view that the Inquiry Officer’s Report does not disclose any foundation to conduct an investigation against CP and there has been no further evidence adduced to suggest that CP has caused or contributed to any alleged service failure in the Vancouver area, and thus respectfully requests that this investigation be terminated as against CP.

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Appendix 1 – CP Grain Volume Press Releases Canadian Pacific delivers for grain supply chain; breaks record in October for shipping Canadian grain and biofuels

November 06, 2018 Canadian Pacific delivers for grain supply chain; breaks record in October for shipping Canadian grain and biofuels Canadian Pacific (TSX:CP) (NYSE:CP) has broken all-time records for the shipment of grain, moving 2.64 million metric tonnes (MMT) of Canadian grain and grain products in October. This makes October 2018 CP's biggest month ever for moving Canadian grain, breaking the record from September 2017. During the month of October CP also set a new record for biofuels shipped. "This accomplishment is a testament to the hard work and dedication of our operating team and the power of our operating model," said Joan Hardy, CP's Vice-President Sales and Marketing – Grain and Fertilizer. "This requires laser-sharp focus on the supply chain details, and close collaboration with customers, elevators and ports. Together, through hard work and open communication, the system has been operating with maximum velocity and fluidity." Through 14 weeks of the 2018-19 crop year, CP shipped more than 7.5 MMT of grain and grain products, and since harvest began in September has averaged more than 5,500 empty railcars to country elevators each week. The supply chain has been able to overcome challenging conditions across the prairies, including an early blast of winter weather in October which caused significant harvest delays and resulted in some grain pipeline congestion. CP reiterates the need for 24/7 operations throughout the entire supply chain to prevent further congestion. "Viterra has received steady and reliable service from CP this fall, resulting in a more fluid and efficient supply chain," said Kyle Jeworski, President and CEO of Viterra North America. "This is what we expect from an important service provider like CP and by working closely together, we can continue driving excellence in our supply chain and ensure that we are well positioned to meet current and future industry demands." CP continues to meet its Dedicated Train Program (DTP) commitments, and is getting positive feedback from its customers. Under the DTP, customers are incentivized to load and unload more quickly, driving increased overall grain movements and benefitting the economy. Customers are investing in the future by upgrading elevator infrastructure with 8,500-foot train capable loop track which results in efficiency gains for both grain shippers and CP. To increase efficiency even more, CP is investing in new high efficiency hopper cars with 500 being delivered by the end of this year. These new cars carry more grain per car, allow for faster loading and unloading, and need less maintenance. In preparation for winter, CP is actively deploying resources and assets and is in the final stages of adding employees and locomotives to meet the needs of our customers across North America.

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This includes additional remanufactured locomotives and hundreds of new operations employees making their way through our training process. Read CP's White Paper: Railroading in the Canadian Winter for more information on everything we do for safe winter operations. CP's Customer Safety Handbook gives clear direction on safe rail operations to ensure CP employees can safely access customer sites in winter.

December 4, 2018 /Calgary, AB Canadian Pacific breaks more grain records; sets new carload record for shipments to Port of Vancouver in November Canadian Pacific (TSX:CP) (NYSE:CP) is proud to announce that November 2018 was another very strong month for the movement of Canadian grain. The company has broken its previous record for carloads of Western Canadian grain and grain products shipped to the Port of Vancouver in a single month. In November, more than 17,150 carloads of Canadian grain and grain products were shipped on CP to Vancouver, a total of 1.54 million metric tonnes (MMT). "CP's operations team continues to deliver for our customers day after day. Vancouver is a key outlet for Canadian grain to move to export markets, and is a very important corridor for our customers," said Joan Hardy, CP Vice-President Sales and Marketing – Grain and Fertilizers. "This record is a testament to the dedication we have to providing service to our customers, and showcases the incredible momentum we have as a company. Once again, our operating model is showing its power." Last month CP announced that October 2018 was the company's best month ever for shipment of grain and grain products, moving 2.64 MMT to all destinations. Overall, CP's November grain and grain products shipments were very strong at 2.50 MMT. Since the fall harvest push started in September, CP has moved 2 percent more grain and grain products than the same period last year. "Working in close collaboration with farmers, producers, ports and the entire grain supply chain, we continue to deliver for Canada's agriculture sector," said Hardy.

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Appendix 2 – CN Embargo Public Notice

View as a webpage

Dear Robert,

We would like to advise you of our plans in preparation for a potential labour disruption at the other major Canadian railroad. The earliest date of a labour disruption would be Monday May 28.

Our first priority at CN is to protect service levels with our existing valued customers and supply chain partners and to ensure the fluidity of our network.

CN's network has seen sequential improvements across all key operating metrics since March. It is our goal to continue to improve and to provide our customers an efficient and reliable service.

In the event of a labour disruption at the other major Canadian railroad, we will immediately take the following actions to avoid impacting our operational performance;

· CN will embargo all loads and revenue empties to and from all their interchanges. · CN will continue to serve dual serve customers – based on our regular run rates. We will not accept additional empties or loads beyond the traffic that is being handled today. · CN will continue to serve CN steamship lines at agreed to allocation levels by port. · The co-production agreement in Southern British Columbia will not be in effect in the event of a strike. CN will continue to serve Vancouver exclusively on CN direct lines.

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· CN will continue to directly serve the terminals of Vanterm and Centerm in the Port of Vancouver.

CN ratified a new collective agreement with TCRC, which represents our conductors and engineers, and will be operating at full capacity.

Please contact your CN account manager if you have any further questions.

In addition, CN will regularly communicate relevant and important shipping information to its customers should a labour disruption become a reality.

Thank you and, as always, we appreciate your business. CN Corporate Marketing

Contact Us Quick Links Sales Center | 1-888-MOVIN-CN eBusiness Login eBusiness | 1-800-361-0198 Customer Center Service Delivery | 1-888-926-7245 Customer Safety Intermodal Logistics | 1-866-896-6601 Our Business

Manage your email preferences Unsubscribe from all emails

This email was sent to: [email protected] CN respects your privacy. Read our online Privacy Statement. CN, 935 de La Gauchetière West Montreal, Quebec, H3B 2M9, Canada

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Appendix 3 – CP Embargo Bulletins

December 10, 2018

Customer Station Bulletin

Customer Advisory – Vancouver Traffic Embargo

Due to congestion at the CN interchange serving the North Shore in Vancouver, and the interchange at New Westminster BC, CP will be issuing an embargo application for specific consignees and commodities in manifest service in an effort to proactively manage the traffic into this congested area. CP is working to minimize impacts to our customers through blocking traffic for CN to help expedite their recovery.

This embargo applies to:

· Ray-Mont Logistics Vancouver, Global Agriculture Trans-Loading, Lynn Terminals Eastgate, KM Canada Marine Terminal, Euro Asia Transload and Fibreco Exports receiving the following commodities - canola, canola meal, flaxseed, special crops and pulp products. · This embargo will go into effect at 0001, Thursday December 13th. The embargo can be rescinded at any time. · Please note, this will not impact unit train service.

For up-to-date information on specific impacts to your shipments or other problem resolution inquiries please contact Customer Service at 1-888-333-8111. You can also reach Customer Service through the Log an Issue tool on Customer Station or via email at [email protected]

CP will continue to monitor the situation and provide updates, we appreciate your patience and support.

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December 18, 2018 Customer Station Bulletin

Carload Network Bi-weekly Update – Week of December 17, 2018 / Nouvelles bimensuelles – Transport de wagons complets – semaine du 17 décembre 2018

CP Weekly Network Update

Service Highlights This Week

CP continues to experience high volume in Alberta and remains focused on improving the network’s fluidity in this region. Seasonal weather is expected across the network this week.

Service Expectations Next Week

CP expects operating conditions to remain favorable across the network.

Asset Forecast This Week

Continue to see solid demand across majority of fleets; demand for Mill Gondolas and Centrebeam Flatcars remain particularly high. Vancouver North Shore congestion is impacting boxcar supply in the western half of the network.

Operational Performance:

Below is a look at the key operational performance categories for carload traffic for the Week Ending December 16, 2018:

Weekly Carloads: 33,116 (previous week: 31,624) Carload On-Time Performance: 64.5% (previous week: 64.0%) Average Train Speed: 22.8 MPH (previous week: 22.9 MPH) Average Terminal Dwell: 6.6 hours (previous week: 6.2 hours)

Markets – New or Notable

Customer Bulletin - Cross border documentation requirements

With the upcoming Holiday season CP would like to remind customers to ensure all customs documentation is in place for shipments crossing borders. Brokers are reminded to file entry in a timely manner to avoid unnecessary delay and shipment holds.

Holiday Service Requirements

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As a reminder to all CP customers who receive local terminal service, please ensure Customer Station is updated prior to December 18 to reflect your service requirements for the upcoming holidays, December 24, 25, 26 and 31 and January 1.

To do this:

· Go to the “Facility Tools” tab in Customer Station · Select “Maintain Facility Profile”

If instructions are not entered and your facility is not accessible on the holiday, charges in Tariff 2 will apply.

Please note regular service applies to automotive plants/facilities, and bulk train shippers and receivers, as your statutory service is managed on a weekly planning basis by your CP shipment planning team.

December 19, 2018

Customer Station Bulletin

Customer Advisory – Vancouver Traffic Embargo Changes

Effective today, December 19, CP will be adjusting our embargo applications; adding a permit provision on bulk products and cancelling pulp products. CP’s shipments of all commodities into Vancouver continue to be impacted by CN caused congestion but we are starting to see slow improvement, in particular with manifest car counts in the Vancouver region. While this will allow CP to lessen restrictions on manifest shipments into Vancouver in the coming days, we will be monitoring the inbound pipeline and only allowing permits when feasible to do so.

CP continues to support CN’s recovery efforts and remains committed to working with CN and our customers to reduce congestion and increase throughput.

CP will continue to monitor the situation and provide updates, we appreciate your patience and support.

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December 19, 2018 Customer Station Bulletin

Customer Advisory – Vancouver Traffic Embargo Changes - Clarification

Due to a number of inquiries regarding our embargo changes today, the following should help clarify the bulletin. A permit provision was added to an existing embargo for canola, canola meal, flaxseed and special crops. The pulp product embargo was rescinded.

December 21, 2018 Customer Station Bulletin

Customer Advisory – Vancouver Traffic Embargo

Due to congestion in Vancouver, CP will be issuing an embargo application for Columbia Containers Ltd in an effort to proactively manage the traffic into this congested area.

This embargo applies to:

· All traffic to Columbia Containers Ltd. · This embargo will go into effect at 0001, Monday December 24. The embargo can be rescinded at any time.

CP will continue to monitor the situation and provide updates, we appreciate your patience and support.

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AAR Embargo Broadcast 2318 ______From: Embargo Permit DB System Sent: Monday, December 10, 2018 9:56:13 PM (UTC-07:00) Mountain Time (US & Canada) To: Brian Townshend Cc: Embargo Broadcasts Subject: Embargo #CPRS002318 has been approved on 12-10-2018

This email did not originate from Canadian Pacific. Please exercise caution with any links or attachments.

======Embargo #CPRS002318 has been approved on 12-10-2018

(This information can also be viewed online at https://urldefense.proofpoint.com/v2/url?u=https- 3A__aarembargo.railinc.com_epdb_searchEmbargoAction.do-3Fstep-3DviewDetails- 26embargoNumber-3DCPRS002318&d=DwICAg&c=xN2- G3cygOpDxk3Nh3luTA&r=zfwnfwvZhJ6SDMuMQSFoCqZEEEUbPmwa0vnc9b08y9E&m=- njr7ulkZhmS19ykhbUsYJr97iXR2GjCU3K0wIaAntk&s=g9JAurHSgySNd5E4TxPvp8BiWsyIFW0ayiRWtb813f 4&e=) # Copyright (c) 2015 Railinc Corp. - All rights reserved. # CPRS-CANADIAN PACIFIC RAILWAY Embargo Number: CPRS002318 Status: Effective Effective Date: 12-10-2018 Expiration Date: 12-10-2019 Allow Permit: No Tier 2 Effective Date: 12-13-2018 Original Effective Date: Roads Invited to Participate: Original Requester : Brian Townshend - Ph: 2049478203x8203 - Email: [email protected] Bypass Local Waybills: No Operating Station Notice: No Effective Immediately: No Include Empty Revenue Cars: No Include All Empty Cars: No Maximum Car Allowed: Commodities:

2611133 (HARDWOOD WOOD PULP, BALED, NOT SCREENINGS, NOT SCRAP, AND NOT POWDERED. MADE FROM SPECIES TO INCLUDE, BUT NOT LIMITED TO, OAK, HICKORY, ASH, CHERRY, GUM, POPLAR AND MAPLE.)

Page | 25 REDACTED - PUBLIC VERSION

2611134 (SOFTWOOD WOOD PULP, BALED, NOT SCREENINGS, NOT SCRAP, AND NOT POWDERED. MADE FROM SPECIES TO INCLUDE PINE, SOUTHERN YELLOW PINE, AND OTHER MISC. SOFTWOOD SPECIES.)

2611135 (WOODPULP, NOT POWDERED, NEC)

2611136 (WOODPULP, NORTHERN BLEACHED SOFTWOOD, KRAFT)

2611137 (WOODPULP, CHEMO-THERMO- MECHANICAL PULP)

2621110 (NEWSPRINT PAPER, BAGASSE OR BAGASSE AND OTHER FIBRES)

2621115 (NEWSPRINT PAPER, FIBRE CONTENT CONSISTING OF NOT LESS THAN 60 PERCENT GROUND WOOD (WILL NOT INCLUDE PAPER WHICH HAS BEEN FURTHER PROCESSED AFTER ITS ORIGINAL MANUFACTURE))

2621215 (GROUND WOOD PAPER, UNCOATED, NOT LESS THAN 60 PERCENT GROUND WOOD FIBRE, IN ROLLS OF LESS THAN 16 INCHES IN DIAMETER OR IN SHEETS MEASURING LESS THAN 336 SQUARE INCHES, INCLUDING CATALOG, DIRECTORY, DRAWING, MANILA, NOVEL, POSTER, PRINTING, TABLET OR WRITING PAPERS, OR OTHER PAPERS, OTHER THAN NAPKIN, NEWSPRINT OR TOILET PAPERS, PAPER TOWELING OR UNFINISHED BLANK WALL PAPER)

2621216 (GROUND WOOD PAPER, UNCOATED, NOT LESS THAN 60 PERCENT GROUND WOOD FIBRE, IN ROLLS OF NOT LESS THAN 16 INCHES IN DIAMETER OR IN SHEETS MEASURING NOT LESS THAN 336 SQUARE INCHES, INCLUDING CATALOG, DIRECTORY, DRAWING, MANILA, NOVEL, POSTER, PRINTING, TABLET OR WRITING PAPERS, OR OTHER PAPERS, OTHER THAN NAPKIN, NEWSPRINT OR TOILET PAPERS, PAPER TOWELING OR UNFINISHED BLANK WALL PAPER)

Geography: Included Locations: Origin: * Destination: CPRS-09703,NORTH VANCOUVER,BC CPRS-09717,SAPPERTON CN,BC CPRS-09720,NEW WESTMINSTER,BC

UNI-DIRECTIONAL Umler Equip. Type : Target All Umler Equipment Types No Weight Restrictions Except These Cars: No Cars In Exception List Embargo/OPSL Umler Element Status: No Umler Element Clearance Code: No Clearance Code Waybill Parties: Target All Waybill Parties Except Waybill Parties Care Of Party - 2011733250000 - WESTERN STEVEDORING COMPANY LTD - null, NORTH VANCOUVER, BC Consignee - 2011733250000 - WESTERN STEVEDORING COMPANY LTD - null, NORTH VANCOUVER, BC

Page | 26 REDACTED - PUBLIC VERSION

Care Of Party - 2011733259000 - LYNN TERMINALS EASTGATE - null, NORTH VANCOUVER, BC

Consignee - 2011733259000 - LYNN TERMINALS EASTGATE - null, NORTH VANCOUVER, BC

Care Of Party - 2030527250000 - OLYMPIA TRANSPORTATION LTD - null, BURNABY, BC

Consignee - 2030527250000 - OLYMPIA TRANSPORTATION LTD - null, BURNABY, BC

Care Of Party - 2091145810000 - EURO ASIA TRANSLOAD INC - null, RICHMOND, BC

Consignee - 2091145810000 - EURO ASIA TRANSLOAD INC - null, RICHMOND, BC

Care Of Party - 2091145818000 - EURO ASIA TRANSLOAD INC - null, NEW WESTMINSTER, BC

Consignee - 2091145818000 - EURO ASIA TRANSLOAD INC - null, NEW WESTMINSTER, BC

Care Of Party - 2091145818001 - EURO ASIA TRANSLOAD INC - null, VANCOUVER, BC

Consignee - 2091145818001 - EURO ASIA TRANSLOAD INC - null, VANCOUVER, BC

Care Of Party - 2091145818002 - EURO ASIA TRANSLOAD INC - null, VANCOUVER, BC

Consignee - 2091145818002 - EURO ASIA TRANSLOAD INC - null, VANCOUVER, BC

Care Of Party - 2420718890000 - WESTRAN PORTSIDE TERMINAL LTD - null, RICHMOND, BC

Consignee - 2420718890000 - WESTRAN PORTSIDE TERMINAL LTD - null, RICHMOND, BC

Care Of Party - 2444622890000 - WESTRAN SERVICES LTD - null, NEW WESTMINSTER, BC

Consignee - 2444622890000 - WESTRAN SERVICES LTD - null, NEW WESTMINSTER, BC

Care Of Party - 2444622898001 - WESTRAN SERVICES LTD - null, BURNABY, BC

Consignee - 2444622898001 - WESTRAN SERVICES LTD - null, BURNABY, BC

Care Of Party - 2444622899000 - WESTRAN INTERMODAL LTD - null, NEW WESTMINSTER, BC

Consignee - 2444622899000 - WESTRAN INTERMODAL LTD - null, NEW WESTMINSTER, BC

Care Of Party - 2452529570000 - EURO ASIA TRANSLOAD INC - null, RICHMOND, BC

Consignee - 2452529570000 - EURO ASIA TRANSLOAD INC - null, RICHMOND, BC

Care Of Party - 2511660050000 - COAST 2000 TERMINALS LTD - null, RICHMOND, BC

Consignee - 2511660050000 - COAST 2000 TERMINALS LTD - null, RICHMOND, BC

Page | 27 REDACTED - PUBLIC VERSION

Care Of Party - 2511660058000 - COAST 2000 TERMINALS LTD - null, VANCOUVER, BC

Consignee - 2511660058000 - COAST 2000 TERMINALS LTD - null, VANCOUVER, BC Cause: Congestions/Accumulation

Cause Detail: Congestion/Accumulation

Note:

Jeffrey J. Usher

Asst. Vice President-Business Services

Association of American Railroads

______

AAR Embargo/OPSL Notes And Permit System (https://urldefense.proofpoint.com/v2/url?u=https- 3A__aarembargo.railinc.com_epdb&d=DwICAg&c=xN2- G3cygOpDxk3Nh3luTA&r=zfwnfwvZhJ6SDMuMQSFoCqZEEEUbPmwa0vnc9b08y9E&m=- njr7ulkZhmS19ykhbUsYJr97iXR2GjCU3K0wIaAntk&s=LgoYbT_R6NShh8pi4NEhhXvVuDKcJmE5jeFIrasw7K s&e=)

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AAR Embargo Broadcast 2418 ______From: Embargo Permit DB System Sent: Monday, December 10, 2018 9:56:35 PM (UTC-07:00) Mountain Time (US & Canada) To: Brian Townshend Cc: Embargo Broadcasts Subject: Embargo #CPRS002418 has been approved on 12-10-2018

This email did not originate from Canadian Pacific. Please exercise caution with any links or attachments.

======Embargo #CPRS002418 has been approved on 12-10-2018

# Copyright (c) 2015 Railinc Corp. - All rights reserved. CPRS-CANADIAN PACIFIC RAILWAY Embargo Number: CPRS002418 Status: Effective Effective Date: 12-10-2018 Expiration Date: 12-10-2019 Allow Permit: No Tier 2 Effective Date: 12-13-2018 Original Effective Date: Roads Invited to Participate: Original Requester : Brian Townshend - Ph: 2049478203x8203 - Email: [email protected] Bypass Local Waybills: No Operating Station Notice: No Effective Immediately: No Include Empty Revenue Cars: No Include All Empty Cars: No Maximum Car Allowed: Commodities: Target All Commodities Geography: Included Locations: Origin: * Destination: CPRS-09700,VANCOUVER,BC CPRS-09703,NORTH VANCOUVER,BC CPRS-09720,NEW WESTMINSTER,BC

UNI-DIRECTIONAL Umler Equip. Type : Target All Umler Equipment Types

Page | 29 REDACTED - PUBLIC VERSION

No Weight Restrictions Except These Cars: No Cars In Exception List Embargo/OPSL Umler Element Status: No Umler Element Clearance Code: No Clearance Code Waybill Parties:

Care Of Party - 2403269260000 - FIBRECO EXPORT INC - null, NORTH VANCOUVER, BC

Consignee - 2403269260000 - FIBRECO EXPORT INC - null, NORTH VANCOUVER, BC

Care Of Party - 2403269269000 - FIBRECO PULP INC - null, NORTH VANCOUVER, BC

Consignee - 2403269269000 - FIBRECO PULP INC - null, NORTH VANCOUVER, BC

Care Of Party - 2437209480000 - GLOBAL AGRICULTURE TRANS-LOADING INC - null, SURREY, BC

Consignee - 2437209480000 - GLOBAL AGRICULTURE TRANS-LOADING INC - null, SURREY, BC

Care Of Party - 2437209488000 - GLOBAL AGRICULTURE TRANS-LOADING INC - null, SURREY, BC

Consignee - 2437209488000 - GLOBAL AGRICULTURE TRANS-LOADING INC - null, SURREY, BC

Care Of Party - 2437209489000 - AGRLIENT AGROLINK ENERPRISES LTD - null, SURREY, BC

Consignee - 2437209489000 - AGRLIENT AGROLINK ENERPRISES LTD - null, SURREY, BC

Care Of Party - 2437883580000 - KM CANADA MARINE TERMINAL LP - null, NORTH VANCOUVER, BC

Consignee - 2437883580000 - KM CANADA MARINE TERMINAL LP - null, NORTH VANCOUVER, BC

Care Of Party - 2488129680000 - RAY-MONT LOGISTICS VANCOUVER INC - null, RICHMOND, BC

Consignee - 2488129680000 - RAY-MONT LOGISTICS VANCOUVER INC - null, RICHMOND, BC

Cause: Congestions/Accumulation Cause Detail: Congestion Accumulation to the North Shore in Vancouver

Note: Jeffrey J. Usher Asst. Vice President-Business Services Association of American Railroads ______

AAR Embargo/OPSL Notes And Permit System (https://urldefense.proofpoint.com/v2/url?u=https- 3A__aarembargo.railinc.com_epdb&d=DwICAg&c=xN2- G3cygOpDxk3Nh3luTA&r=zfwnfwvZhJ6SDMuMQSFoCqZEEEUbPmwa0vnc9b08y9E&m=mrxXOkIn8xQhr waXUckOy7ZZXHo5ZlLbfoC13p5vDR4&s=aNfDf82hH1nVArOkrgF7D8NT_H6GaV9QQ7bepJHZwyU&e=)

Page | 30 REDACTED - PUBLIC VERSION

AAR Embargo Broadcast 2518 ______From: Embargo Permit DB System Sent: Friday, December 21, 2018 10:06:49 AM (UTC-07:00) Mountain Time (US & Canada) To: Brian Townshend Cc: Embargo Broadcasts Subject: Embargo #CPRS002518 has been approved on 12-21-2018

This email did not originate from Canadian Pacific. Please exercise caution with any links or attachments.

======Embargo #CPRS002518 has been approved on 12-21-2018

# Copyright (c) 2015 Railinc Corp. - All rights reserved. # CPRS-CANADIAN PACIFIC RAILWAY Embargo Number: CPRS002518 Status: Effective Effective Date: 12-21-2018 Expiration Date: 12-21-2019 Allow Permit: No Tier 2 Effective Date: 12-24-2018 Original Effective Date: Roads Invited to Participate: CN,BNSF Original Requester : Brian Townshend - Ph: 2049478203x8203 - Email: [email protected] Bypass Local Waybills: No Operating Station Notice: No Effective Immediately: No Include Empty Revenue Cars: No Include All Empty Cars: No Maximum Car Allowed: Commodities: Target All Commodities Geography: Included Locations: Origin: * Destination: CPRS-09700,VANCOUVER,BC CPRS-09720,NEW WESTMINSTER,BC UNI-DIRECTIONAL

Page | 31 REDACTED - PUBLIC VERSION

Umler Equip. Type : Target All Umler Equipment Types No Weight Restrictions Except These Cars: No Cars In Exception List Embargo/OPSL Umler Element Status: No Umler Element Clearance Code: No Clearance Code Waybill Parties: Care Of Party - 2074852930000 - COLUMBIA CONTAINERS LTD - null, VANCOUVER, BC

Consignee - 2074852930000 - COLUMBIA CONTAINERS LTD - null, VANCOUVER, BC Cause: Congestions/Accumulation Cause Detail: Congestion/ Accumulation

Note: Jeffrey J. Usher Asst. Vice President-Business Services Association of American Railroads

______

AAR Embargo/OPSL Notes And Permit System (https://urldefense.proofpoint.com/v2/url?u=https- 3A__aarembargo.railinc.com_epdb&d=DwICAg&c=xN2- G3cygOpDxk3Nh3luTA&r=zfwnfwvZhJ6SDMuMQSFoCqZEEEUbPmwa0vnc9b08y9E&m=kRMr2rcnwgNnp Qv6FR0ff_wjlgo-do7AF1mvo_SX-vw&s=b7QHT6_r9-uPtWcmTfhNAla3Q0LEgBEtpS32Y3k_zEw&e=)

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